Gypsy and Traveller Site Options

Comment

Representation ID: 55882

Received: 08/08/2013

Respondent: Warwickshire Wildlife Trust

Local Wildlife Sites (LWS) are core areas for nature conservation, underpin local ecological networks and make significant contribution towards national and local biodiversity targets and objectives. NPPF assigns them protection which must be upheld during site selection process.

Eight of the identified sites include or are adjacent to a statutory or non-statutory LWS. Sites well away from a LWS, or which have no significant effects on a LWS should be selected. Only where justified, sites inclusive of or adjacent to a LWS should be selected and must safeguard the LWS and provide mitigation in accordance with NPPF (paragraph 118) eg buffer zones. Gypsy and Traveller developments should be able to accommodate mitigation measures. However, need a policy which requires effectively designed and implemented mitigation as part of planning application process. This does not exist in Warwick at the moment.

Local Wildlife Site should be clearly identified as a development constraint where appropriate. Pitch densities on preferred sites should reflect presence of LWS and the required long-term mitigation measures.

Local Plan needs a robust policy for the protection and enhancement of biodiversity reflecting NPPF paragraph 113 of the so that sites receive appropriate protection and provisions which seek enhancements to create coherent and resilient ecological networks.

Comment

Representation ID: 56184

Received: 08/08/2013

Respondent: Warwickshire Wildlife Trust

There are Potential Local Wildlife Sites (pLWS) in or adjacent to eight of the identified sites (GT02, GT04, GT07, GT09, GT10, GT12, GT19 and GT20) and although not fully surveyed and assessed should be treated as a Local Wildlife Site unless survey and assessment against standardised criteria suggests otherwise.

The presence of a LWS could influence the type or density of development so it is important its status is determined from the outset. This will provide robust justification for conserving the site and/or amending site densities.

Therefore evidence base for the Plan should be updated so all pLWSs in or adjacent to above referenced site allocations are appropriately surveyed and assessed and sites fulfilling LWS criteria are clearly indicated as such.

Comment

Representation ID: 56185

Received: 08/08/2013

Respondent: Warwickshire Wildlife Trust

Section 40 of the Natural Environment and Rural Communities Act 2006 (NERC)and paragraph 117 of the NPPF, place duty on the Planning authority to preserve and promote biodiversity. All identified sites have potential to include habitats and species of principal importance for nature conservation and are also likely to be priorities within the Local Biodiversity Action Plan.

To comply with statutory duty and national policy, local authority needs robust and up-to-date ecological information for all site allocations so that priority habitats and species are identified and acknowledged before any decisions are made on development ie pitch densities which could in turn impact on habitats or species.

To ensure future planning applications have appropriate regard to protection and enhancement of biodiversity the Plan needs a specific policy to embed these principles as current Warwick District Local Plan does not have one.

Comment

Representation ID: 56186

Received: 08/08/2013

Respondent: Warwickshire Wildlife Trust

GT01 is entirely within land needed to provide ecological compensation for the Coventry Gateway development proposals. The compensation scheme maintains a connective ecological corridor along the River Avon corridor and buffers and extends the Siskin Bird Sanctuary LWS. Deviation from this approved scheme will make the Gateway proposals unacceptable and require amendments to the planning conditions and obligations. The adverse cumulative effects on biodiversity of allocating this site are likely to be significant and should be afforded sufficient weight in the decision making process.

Comment

Representation ID: 56187

Received: 08/08/2013

Respondent: Warwickshire Wildlife Trust

The Sustainability Appraisal identifies negative effects on biodiversity for almost all of the preferred Gypsy/ Traveller site allocations. Plan must demonstrate how it complies with the NPPF principles of supporting and enhancing nature and local environments. Believe that this can only be achieved if all development sites demonstrate a positive and proportionate contribution to establishing a coherent and resilient ecological network for the district.

Plan should have a policy requiring development sites to contribute towards enhancing district wide networks of biodiversity and green infrastructure (GI) and take into account the Warwick District GI Strategy and Warwickshire, Coventry and Solihull Sub-regional GI Strategy and associated Biodiversity Offsetting appendix.

Comment

Representation ID: 56188

Received: 08/08/2013

Respondent: Warwickshire Wildlife Trust

GT01 is entirely within land needed to provide ecological compensation for the Coventry Gateway development proposals. The compensation scheme maintains a connective ecological corridor along the River Avon corridor and buffers and extends the Siskin Bird Sanctuary LWS. Deviation from this approved scheme will make the Gateway proposals unacceptable and require amendments to the planning conditions and obligations. The adverse cumulative effects on biodiversity of allocating this site are likely to be significant and should be afforded sufficient weight in the decision making process.